Democratic campaign consultant D'mitri Kosub on Tuesday filed an ethics complaint against embattled Councilwoman Elisa Chan, alleging she violated a city directive by using her taxpayer-funded office to hold a political meeting.

At the heart of the complaint are the contents of the secret recording made May 21 when Chan and several staff members discussed her opposition to the proposed nondiscrimination ordinance.

Kosub cites several instances, both in the recorded conversation and in San Antonio Express-News reports that quoted Chan staff members, as evidence that Chan and her aides were discussing politics rather than governance.

“When taken together, these statements indicate that the May 21, 2013, staff meeting was conducted for the partisan political purpose of preparing statements and policy to specifically appeal to potential voters in an upcoming Republican primary,” Kosub wrote in his complaint.

“This complaint alleges that a partisan political purpose was served because the discussion focused on how statements, actions, or policy administered by the office would be received by the partisan political group of voters who participate in the Republican primary or those voters who the councilwoman perceives constitute her partisan political base,” it said.

Chan, who represents District 9, said: “I'm confident that I did not violate any city ordinance.”

The administrative directive that Kosub says Chan violated prohibits political activity by city employees.

It prohibits “the use of public employees and city resources for political purposes, and to avoid any appearance of bias or favoritism in carrying out public policy.”

In his complaint, Kosub accuses Chan of engaging her city staff during city time, on city property, for a political purpose.

He also alleges Chan “failed to avoid the appearance of bias and/or favoritism by allowing the discussion to focus on appealing to her political, voting base.”

Kosub filed the complaint with the city clerk Tuesday. The city attorney's office typically reviews complaints to ensure the Ethics Review Board has jurisdiction over the allegations and forwards the complaint to that citizen board if it does.